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FOR THE DISTRICT OF COLORADO Civil Action No - How Appealing

FOR THE DISTRICT OF COLORADO Civil Action No - How Appealing

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(As Against Faegre & Benson, Fischer, & Judy Heumann)<br />

59. Plaintiff incorporates by this reference each of the<br />

previous paragraphs. Plaintiff repeats and re-alleges each and<br />

every allegation contained in the previous paragraphs.<br />

60. Faegre & Benson, Fischer and Heumann willfully<br />

disobeyed the Judgment On Remand by the Fabricated Order.<br />

61. Faegre & Benson, Fischer and Heumann interfered with<br />

the ability of the Court to function properly by the Fabricated<br />

Order.<br />

62. As a direct and proximate result of foregoing, Faegre &<br />

Benson, Fischer and Heumann should be held in contempt, and ISR<br />

awarded damages, together with interest, costs and reasonable<br />

attorneys’ fees and declaratory and/or injunctive relief.<br />

NINTH CAUSE <strong>OF</strong> ACTION<br />

(Declaratory Relief)<br />

(As Against All Defendants)<br />

63. Plaintiff incorporates by this reference each of the<br />

previous paragraphs. Plaintiff repeats and re-alleges each and<br />

every allegation contained in the previous paragraphs.<br />

64. There is an actual controversy between the parties.<br />

65. A judicial determination is required regarding the<br />

Fabricated Order. Defendants have taken the position that the<br />

Fabricated Order is a true and correct Order of this Court and is<br />

properly filed with the Boulder County Clerk and Recorder. ISR<br />

has taken the position that the Fabricated Order was never issued<br />

or entered by this Court and was not properly filed with the<br />

Boulder County Clerk and Recorder and should be voided.<br />

10

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